- 23 U 4 02:06p Paul A Ironside, --_- M D __ _ _ . . - 760 3 4 6 5 3 4 5

Declaration of Paul A. Ironside, MD

I am a citizen of the State of California Ciounty of Riverside, USA practicing at 74-399 Highway 1 1 1 Palm Desert, CA 92260, age 67, in good health and willing to testifjr. II am a licensed to practice medicine and surgery in California - C2923 1 (Exhibit #1)

In the mid 80's I came up with an idea to build in Simi Valley a total outpatient facility. Four other physicians joined me in this effort. We bought land just off the 1 18 Freeway on Sycamore Avenue a block from Simi Valley Hospital (SVH). At this point we asked the Hospital to join with us, but they wlere not interested. We became partners with Balboa Construction headed by Michael Goland. When the building was approximately 85% completed Balboa Construct:ion went bankrupt. Nothing happened for 6 or 7 months while we tried to entice any ventwe capital group or hospital corporation to help us. We once again went to Simi Valley Hospital and the President, Robert Carmen. They joined us becoming a 51% owner and the managing partner.

Around this time our group bought out one of our partners secondary to an internal conflict.

The Aspen Center was completed. It contained a complete radiology department, a dedicated building with a MRI, three surgical suites, multiple office suites, a medical laboratory, etc. The Simi Valley Hospital, because they controlled insurance contracts, ran the Center into bankruptcy. The four of us lost evaything. Two of us over $500,000 and the other two lost $350,000. Aspen Center became very successful. (Exhibit #2) Robert Carmen made all. Hospital decisions, but remaining aloof by having his administrator, Allan Rice front for him. I, as the leader of our group, tried many things to keep Aspen afloat. All were unsuccessful. The Hospital was angry with all of us and threatened to sue us and to push me into peer review. They did not sue us, but they did force me into a peer review process. Only one of the physicians in our group has remained on the staff, but his stature was diminis'hed since HMO's that the hospital was involved with directed orthopedic consults elsewhere. The other two were radiologists whose contracts were not renewed.

Susan F. Van Hall from JefFer, Mangels, :Butler & Marmaro was both the hospital attorney and acted as the Medical Staff attorney, an obvious conflict of interest. She engineered with the help of a few strategically placed Hospital controlled physicians to bypass the Medical S W B y Laws and have multiple cases brought before a Judicial Review in order to have my vascular surgical privileges reqoved. The charge was that my complication rate was excessive. Approximately half of the cases were vascular access procedures done on renal dialysis patients. These patients are quite ill, many with advanced diabetes mellitus and muItiple medical problems, including advanced atherosclerosis. These graEts are the bane or vascular surgeons, since their grafts are prosthetics and they fail frequently. At that time I[ was doing about 85-90% of the renal access work at Simi Valley. The nephrologist Kant Tucker, MD was happy with my

- L 3 u 4 u z : u ‘ / p raul H Ironside, MI) -- . -- 760 346 5345

services, He two other vascular surgeons he could have gone to. When these cases were lumped with my other vascular procedures my complication rate was naturally high,

I went to the California State Court in 1993 in Ventura to try to get an injunction, but it was thrown out because the administrative remedies had not been exhausted.

It was about this time that the head of the anesthesia department Alan Heng, MD got arrested for cocaine. He was placed in jail and then a rehab facility. The only thing we physicians at the Hospital knew was that he was “away”. The Chief of Staff at that time was Martin Wareham, MD. When Dr Heng was released after a short stay Dr. Wareham told the Medical Executive Committee that all was OK and that Dr. Heng was to return to his regular anesthesia duties. Atul Aggwal , MD asked what problem he had had and the cocaine arrest came out. Dr Heng was placed back in his regular rotation of giving anesthesia as if nothing were wrong. I then knew why Dr. Heng was frequently going to the bathroom in the middle of cases and allowing the circulating nurse to watch his patients. I was the only surgeon who refused t:o allow him to give anesthesia until his entire rehab program was completed. The administration and especially Dr. Waxeharn were very unhappy with my decision.

Dr, Wareham is the son of the Chief of Thoracic Surgery at Glendale Memorial Hospital a flagship of the Adventist system. Knowing the nepotism in the Adventist system, why was he in Simi? It is my understanding that he got caught with cocaine and subsequently relegated to Simi. He also claimed lto be Dr. Heng’s best friend - very unlikely since they have no si.mi1a.r interests except cocaine. I can’t prove this, but 1 am sure it can be.

A judicial review was conducted in 1992, for six nights over a couple of months time. Ajury of Hospital physicians, picked by Ms Van Hall and the new Chief of S M , were present. Dr. Wareham was the only physician that Ms Van Hall could find to represent the Hospital. There was an attorney acting as moderptor and decision-maker should any procedural questions arise. The moderator was Jesse Miller. When Ms. Van Hall graduated from law school she went to work: for Music, Peeler & Garrett. Mr. Miller was her mentor at that firm. At Ms Van Hall’s requests the scheduled dates for the meetings were changed several times for unusual reasons. Every time Ms Van Hall made a request it was granted. Every time I made one, it was refused. This is a glowing example: The By Laws stated that at the conclusion of the hearing proceedings either party could submit a summary of their position. It had to be submitted by a certain number of days after final testimony. I wrote a suunmary, which took a week to prepare and turned it in on the afternoon of the last day. A few days later Mr. Miller called to tell me that he had extended the time for Ms Van Ha11 to submit one. I found out only several years later the connection between Jesse Miller and Van Hall.

AAer the first session the new Chief of Staff, Atul Aggarwd, MD, refused to permit any more Staff monies to be used for this process. The Hospital gladly picked up the costs - which were horrendous. And at the last meeting after another Van Hall delay they hired a substitute advocate - the Chief of Vascular Surgery at USC.

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The jury of my peers exonerated me. The decision went to the Medical Executive Committee who agreed with their decision and sent it to the Hospital Board. Ms Van Hall decried their decision since it was not in a legal form - listing every case and giving their reasons for deciding in my favor. They refbsed stating that they had spent an inordinate amount of time, listened to all the arguments and rendered their verdict and they all agreed. The Medical By Laws specifically stated that the judicial reviews were not to be conducted like a courtroom trial.

In March or April of 1993 I received notice that I was under “ s m a r y suspension” for rend access surgery. Ms Van Hall engineered this in a Medical Executive Committee meeting. Most Committee members had no understanding of the consequences regarding this ruling. “Summary Suspension” is reserved for those situations where a physician is impaired - alcohol, drugs, mental disease, etc. I was stili performing carotid, aortic, peripheral bypass and thoracic surgery during this period. Several weeks passed before I was permitted to meet with the Medical Executive Committee. The Committee immediately reinstated my privileges, but since a month had elapsed an 805 report was to be automatically generated. She screwed up. It was over 6 months before she realized that this report had not been sent in.

The Hospital Board was chaired by Robert Carmen and consisted of about five other members of the community none of whom were physicians. I was called to the Aspen Center to meet with them. None of the Board members except Robert Carmen, knew that I had conceived of the building and medical programs that surrounded them. A couple of months later Ms Van Hall informed nry lawyer that the Board wanted to do it all over again on the basis that the first jury of peers had not performed their duty properly.

h late September of 1993 I was told that a new hearing would take place in mid October. I explained that I was not available at that time since I had a planned vacation, but I would be available in November. I was subsequently told that I would be tried in my absence. Ms Van Hall had previously and frequently moved meeting dates all over for her convenience. Then she hired physician jurors not on the Hospital Staff. She did not want to take any chances and lose again.

In late 1993 at the behest of a friend who had been the administrator of Westlake Community Hospital and had been in Tennessee for the past several years called again asking me to come to Tennessee to practice. My children were all through college and successfully employed, my medical practice had been ruined at Simi Valley Hospital. I went to Tennessee. In December of 1993 Ms Van Hall found out where I was and sent an unsolicited letter to the Scott County Hospital1 strongly suggesting that I was a bad surgeon and that they should look further into t h e matter. The Chief of Staf€Atul Aggarwal, MD was asked to sign t h i s letter on two occasions, but refused. Ms Van Hall who authored the letter waited until January of :I 994 and had the new Chief of Staff Harry Dnunrnond, MD sign it. At th is time I had1 moved from Scott County Hospital to Morristown, TN and Lakeway Hospital - owned by the same corporation that owned

r c 3 U L ~ uc:Ufp raur H lronside, MD . - 760 3 4 6 5345 P

Scott County Hospital. The population of Scott C!ounty was not sufficient to maintain a practice of thoracic and vascular surgery. I was an outsider with no friends. Simi Valley sent them all the adversarial materials. Lakeway canceled my contract ($12,00O/rnonth). I had joined the staff of the other hospital in town, but things were not going well and I resigned from the staff.

In J a n u q of 1997 I was notified that SO5 reports were filed after the second trial, which I was not present. The California Medical Board was investigating, I was heading to court. At a pretrial meeting I was oeered a “de:al”. I declined to the amazement of the Judge and a two-week trial was held by the Medical Board of California - Division of Medical Quality - Department of Consumer Affairs by the Attorney General for the Medical Board. The Board hired a vascular surgeon of good reputation, These were all the same peer review cases I had been tried for in 1992 and 1993 at SVH. I was totally successful. The California Medical Board adopt4 the decision of Judge B. Dash, Administrative Law Judge. All charges were drolpped. (No. 05-93-33243; OAH No. L- 1997090037) (J3xhZbit #3)

The Decision was sent to Simi Valley Hospital who was given 30 days to challenge. They did not

Prior to this I had contacted Judy McCarthy an attorney in ’93 in Knoxville, TN, and she initiated a lawsuit in Federal Court against S h i Valley Hospital. They first tried to have it moved to CA, but were refused. Next they hired Senator Howard Baker’s law firm and were successful in having the cases throlwn out. An appeal was finally heard in the Federal Court of Appeals in Cincinnati in 1998. I begged Mrs. McCarthy to enter into the court record the Decision of the California Medical Board. She would not. I have always wondered, why not. The excuses or reasoning she gave sounded hollow. The suit had to do with the SVH sending the unsolicited lletter. I had been vindicated from the charges that Ms. Van Hall created. The appeal was lost and I was unable to file a suit in California. (Exhibit #4)

There was a series of articles in the Los ALngeles Time written by Tom Gorman and Eric Lichblau regarding the Adventist system. The one dated,August 13, 1998 showing how they treat physicians who don’t agree with them (Exhibit #5) Their method of control in Simi Valley was to give key physicians, who were on the Medical Executive Committee, contracts for “directing” pulmonary care, ICU, rehabilitation, etc., in exchange for their votes. They were all aware that those contracts could and would be taken from them if they didn’t play ball.

I lost my reputation, ability to make a living practicing in my area of expertise - thoracic and vascular surgery, lost millions of dollars of income, ran up costly legal expenses and was forced into banEauptcy.

It is my understanding that Ms Van Hall and the same administrative persons in the Western Adventist Hospital group have and are atttempting to ruin the reputation and medical practices of physicians in California.

- c3 u4 uu:uup raul H Ironside, MD 760 3 4 6 5 3 4 5

1. 2. 3. 4. March 24,2004. 5. n

22, I declare under penalty of perjury under th,e laws of the State of/California that the foregoing is true and correct. This declaration was executed in Riverside County on

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Paul A Ironside, M D -- a r 25 0 4 02 :07p - -- -

Exhibit #i 1

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Curriculum Vitae

ar 2 5 0 4 02:08p Paul A Ironside, . MD ^ _ _ _ -.- - -

Name:

Birthplace:

Date of Birth:

Home:

Phone: Facsimile: Cell: E- Ma 51:

CURRICULUM VITAE

Paul Allan Ironside, Jr., M.D.

Camden, New Jersey

September 29, 1935

44-406 Royal Lytham Drive Indlo, CA 92201 7602004987 7602008537 7609890544 pironside@prodigy.net

760 3 4 6 5 3 4 5 P.7

Education

High School Haddonfield Memorial High School Haddonfield, NJ

Graduated 1953 Mercersburg Academy Mercersburg, PA

Graduated 1954

Graduated BS D e g r e e 1958 College Washlngton and Lee University

Medical School Hahnemann Univers i ty Philadelphia, PA

Graduated MD Degree 1962

Graduate Training

Internship

Resid en cies

West Jersey Hospital Camden, NJ Rota ti n g July 1962 - June 1963

Hahnemann Univers i ty Hospital Philadelphia, PA General Surgery July 1963 - June 1964 Chief: Jack Cole, M.O.

Paul fl Ironside, M D -- ar 25 0 4 0 2 : 0 8 p - 760 346 5345

Licensure:

M.D. N e w Jersey 1963 - 1967 ,/ 1995 - 1997 MA19653 M.D. California 1963 - 2005 M.D. Tennessee 1993 - 2003 Radiography and Fluoroscopy X-ray Supervisor and Operator Private Pilot - Multi-Engine Land, Xnstrument

C29231 MD024964

Board Certification:

Recommended by John Y. Templeton, 111, M.D., for the General Surgery Boards and by John Jones, M.O., for the Thoracic Boards. Successfully completed the written examination for the General Surgery Boards in 1968. Fellow American College of Angiology

Society Memberships:

Ventura County Medical Society California Medical Association American Medica I Association Associate Fellow of the American College of Angiology Fellow of the Internal College of Angiology Lakeway Medical Society

Articles:

JJ oron c y Arterv Anastomosis - a Non- Suture Technia ue Paul A. Ironside, M.D., Victor Satinsky, M.D. Hahnemann Clinical Research, 1961

A New Method of Pre-Clottina Fa bric Prosthesis Peter B. Samuels, M.D., Paul A. Ironside, M.D., Mark M. Kartchner, M.D. The American Journal of Surgery, 138:238; 1979

Human Growt h Hormone - recombinate Paul A. Ironside, M.D. Newsline, 1:l; 1996

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Pennsylvania H ospita I Philadelphia, PA General Surgery July 1963 - June 67 Chief: John Y. Templeton, 113, M.D.

Hospital of the Good Samaritan Los Angeles, CA Thoracic and Cardiovascular Surgery June 1967 - September 1968 Chief: John Jones, M.O.

Tea chi ng Respond bi I5 t ies:

Medical Students Hahnemann University Hospital - wards Medical Students Pennsylvania Hospital - wards Nurses Training Course Heart Care Unit Hospital of the Good Samaritan Medical Staff Lectures - Thoracic and Vascular Surgery Topics

Westlake Hospital - Westlake, C A Simi Valley Hospital - Simi Valley, CA Palmdale Hospital - Palmdale, CA Tarzana Hospital - Tarzana, CA

Continuing Medical Education - recent:

Harvard Medical School - Angioscopy

Kendalf Regional Medical Center - Endoscopy, Thoroscopy

Harbor - UCLA Medical Center - Endovascular Surgery Symposium

University of Texas Southwestern Medical Center a t Dallas Southern Association for Vasciular Surgery Annual Conference

Vanderbilt University Medical School

April 1989

September 1991

December 1993

January 1995

Nashville, TN Drug Prescribing course August 2000

Ambulatory Treatment of Varicose Veins Las Vegas, NV August 2002

P . 9

Military Service:

Classification 4A - Solo Surviwing Son

a r 25 0 4 02 :08p P a u l fl Ironside, MD ~- - 760 3 4 6 5345

Practice :

Thoracic and Vascular Surgery 1969 - 1993 in Southern California (Thousand Oaks, Westlake Village, San Fernando Valley and Antelope Valley)

Thoraclc and Vascular Surgery 1994-1995 in Oneida and Morrlstown, Tennessee

Famlly Practice and Phlebology 1995-2001 in Morristown, Tennessee

Family Practice and Phlebology 2002 - Present in Palm Desert., Ca I if0 rn ia

Westlake Community Hospital 4415 S. Lakeview Canyon Road Westlake Village, CA 91361

West Valley Hospital 22141 Roscoe Boulevard Canoga Park, CA 91304

Tarzana Regional Hospital 183 2lClarkStreet Tarzana, CA 91356

Lakeway Regional Hospital McFarIand Drive Morristown, TN 37814

Northridge Hospital Medical Center 18300 Roscoe Boulevard Northridge, CA 91328

Antelope Valley Hospital 1699 West Avenue J Lancaster, CA 93534

West H i l l s Hospital 7300MedicalCenter Drive Canoga Park, CA 91307

Antelope Valley Hospital 1600 West Avenue 3 Lancaster, CA 93534

Simi Valley Hospital Sycamore Drive Simi Valley, CA 93065

Morristown-Hamblen Hosp. West 4th North Street Morristown, TN 37814

Lancaster Community Hospital 43830 lofh Street West Lancaster, CA 93534

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h t t D : / /w ww,rfkmustdie.com/chaote r o ne /bo d v :l.html

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Exhibit #if 2

Aspen Center

760 346 5345 p . 1 3

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'. ..- Aspen Center

Outpatient Surgery Center & MRI Fslcifity

A regional prototype outpatient care medical facility located in Simi Valley, Calffiornia. Support services include a same-day surgicenter for cases which in the past required overnight stays, diagnostic imaging center with a wide complement of procedures are performed such as ultrasound, mammography, CT scanning, fluoroscopy, arid X-ray.

Clinical lab services, the latest Endoscopy lab and gastrointestinal lab, Home Health Center, Breast Center, Pain Management Center and &lo- Rectal Center round out the comprehensive one-stop patient visit within a holistic setting.

The main building entry creates a focal point Ifor community adivities and festive events which require public space.

Open since January 1989, the Aspen Center Medical Complex successfully brings together humanistic patient services, and efficient, technologically advanced facilities in a dramatic architectural setting. Aspen Center's architect, J. Paul Lindblad, Principaf of Lindblad Architects, expressed and

a r 25 04 0 2 : 0 8 p Paul A Ironside, M D Lindblad Architects - Aspen Center

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refined the sleek glass and concrete high-tech design theme to complement state-of-the-art outpatient support and Magnetic Resonance Imaging (MRI) equipment, the most technologically advanced diagnostic tool available to medicine today.

Clear room dimension design requirements for the Main Building (comprising diagnostic service and treatment) generated a typical 24 foot wide by 36 foot deep structural bay. A 45" angled, 30-fOOt wide, 36-foot talll main public waiting and patient entry reception penetrates the northwest building corner and features a two-story reflective glass, 50-foot long skylight and exposed glass elevator. Nova Engineering designed a long span post-tensioned concrete frame for the main building to allow critical room dimensions and flexibility, wood frame construction for the MRI building to minimize magnetic field interference, and steel framing to allow clarity in the main entry and MRI entry arcade.

Storms and Lowe contributed mechanical and electrical engineering experience required for t h e special systems and sophisticated support facilities. Jones Construction Management provided construction management services based on a design-build approach to best answer the project sequencing and construction problems. With a ratio of 31,620 net square feet to 35,500 gross, the 89% efficiency rate of the Aspen Center is a competitive rate for t he medicenter, a medical ofFice building prototype. The Architect and consulting engineers worked closely to minimize the volume of non- usable space in various ways. For example, a glass curtain wall was placed over a clear span concrete moment-resisting structural system to free core and shell areas for greater space planning efficiency. Heating and cooling equipment was located on t h e roof top to increase net usable area inside. Public restrooms were centralized where possible to avoid any annoying interference experienced by departments.

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Page 2 of 6

A Welcoming Space

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Lindblad Architects - Aspen Center 760 3 4 6 5345 P * I-'

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The modernist, sleek bronze-reflective glass and post-tensioned building structure sports an impressive two-story glass enclosed elevator within a mall with fountains, notable works of art and plantings which combine to give the patient a sense of wellness that blends with the area's progressive and friendly spirit.

The specific mix of Aspen Center's core services: administration systems, lab services, endoscopy services, home health care, same day surgeries, diagnostic imaging center, MRI, and a future cardiovascular/catheterization lab define the Center as a leading catalyst for changing traditiona health care systems in the future to more economical, faster, simpler diagnosis, treatment, and recovery. Ambulatory patier care and surgery reduce the need for overnight facilities. The

t - -

methodology is particularly suited to the lifestyle and consumer demands of a n aging national "baby-b1oomer" population that generates an corresponding increase0 patient load.

High Tech Diagnostics

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This pioneering medical center offers residents of the West San Fernando Valley and Ventura County one of t h e first installations of Magnetic Resonating Imaging (MRI), the state-of-the-art nonevasive diagnostic tool.

I n.s id e th e new offices ~ of L i nd bl3.d. Arch i te (: ts

MRI is the most advanced diagnostic tool avaitable today which allows the medical clinician to view the interior of the human body with a superior method than X-rays because no radiation is used. MRI images have much better resolution than CT scans and are able to discern different body tissues in healthy and diseased conditions without making an incision. MRI hardware configuration is a cylindrical magnet with a bore large enough to slide a patient through on a moving table. The nuclei of our body's biochemical elements, such as hydrogen and carbon, have magnetic properties. When a uniform magnetic field is applied, bulk magnetization is created parallel to the field. A second magnetic field is applied rotating with the nuclei's unique Larmor frequency which is based on properties of the nucleus and the strength ofthe applied magnetic field. Radio frequencies (RF) are applied (as gradients) in sequential pulsations on the nuclei defining the irnage "slice" and causing them to skew. After the pulses are turned off and on, the nuclei tilt returns to its original position, resonating faint radio signals (Free Induction Decay - FID). Reading FID signals using Fourier transforms, a computer can pllot their location and produce an image of the body's interior and its biochemical nature.

St. Jane's Church .Interior-Renovation

As can be expected, being surrounded by the magnet's bore and the sound of emitting radio signals c a n be a frightening

ar 25 04 02:09p Paul fl Ironside, MD Lindblad Architects - Aspen Center

760 346 5345

experience, especially for the uninitiated. "To diminish such fears," comments Architect Lindblad, "We conceived the Aspen Center to elicit the openness and vitality required to form a sense of well-being for patients; and visitors." The Center's design underscores the rolling hills and open expanse of Simi Valley. Lindblad points out that while an architect's immediate response to the design problem might have been a different building style, the center's location within Simi Valley's medical campus and rapidly expanding area, and the need for the building to identify visitors with the Center's leading technology made high-tech the suitablle architectural response.

The Ambulatory Surgery Department lhas three surgery suites with the amenities of a good acute care hospital. Day surgical procedure patient flow begins at the tvvo-story entry lobby check-in area. Patient traffic continues into the locker area, through patient preparation into surgery suites, recovery and finally back to the locker area. Surgery patients leave the building using a dedicated exit. Home Health Care provides personal attention and case to patients whose condition prevents a visit to the Center. Services include high-tech nursing, pulmonary and respiratory therapy, chemotherapy, insulin therapy, paranteral nutrition, arid intravenous therapy. Medical equipment and supplies for home use can be purchased from the facility.

The Occupational Care Center provides emergency treatment specializing in industrial accidents on ,a IO-hour day basis. The Radiology Department, in the main building, offers radiological diagnostic tests, ultrasound, and mamimography, plus a variety of digital subtraction angiography and computerized tomography (CT scan). The emission tomography unit is one of four installations in Southern California. Aspen Center offers new treatment modalities beyond the core surgical and diagnostic services including: the Breast Center, featuring a cancer awareness program, diagnostic techniques and specialized treatment; the Pain Management Center, focussed on evaluating a patient's medical, psychological, and physical factors to determine the cause of pain; and the Colo-Rectat Center which provides comprehensive colon cancer screening and the most current technology for identifying and treating all rectal problems. Departments on the second floor include general office areas and future plans for a cardiovascular/catheterization lab. Robert Zasa, of Ambulatory Systems Development based in Glenclale, whose projects span the U.S. coordinated the development of the Center's services. Says Mr. Zasa: "We brought ambulatory care multiple diagnostic sewices in one place which complements the Adventist Hospital in-patient care nearby."

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a r 25 04 02:lOp Paul A Ironside, M D Lindblad Architects - Aspen Center

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The Aspen Center project concept was originated by Dr. Paul Ironside, a thoracic surgeon who then contacted Drs. Aucreman and Hebbard. Together they created a partnership to build an independent medicenter with full diagnostic and treatment capability. The original physician planning group purchased the Aspen Center's building site and finalized partnership agreements with the Adventist Hospital. Lindblad Architects, an architecture firm with a health-care facility emphasis located in Valley Glen CA was selected to design t h e complex and to obtain various jurisdictional approvals, The Aspen Center epitomizes the rapid change occurring in today's health care delivery system. Third-party payors (Medicare, Medical, and other health insurers) have passed along budget cutbacks to health care providers (physicians) through reimbursement restrictions. Alternate, Mess expensive health care delivery, best characterized by outpatient diagnostic and treatment centers have the highest ratilo of payment dollars to billed charges. Heafth care providers hlave responded to this trend by establishing free-standing , non-hospi tal based medicenters such as the Aspen Center to maintain a marketshare of the health care industry.

Colfax-Magnolia.Corner Commercial Mixed Use Rejuvenation

B-afdwin-Park Condo-minium&

Address Telephone €-Mail

Lindblad Architects (818) 785 ARCH General Information: Suite 11 OA (2724) info@Iindbladarchitects.com 14547 Titus St ree t Panorama City, CA Client Support: 91402491 9 support@lindbladarchitects.com

(81 8) 785- 8091

p. 1' Page 6 of 6

Last Updated 10-08-2002 Copyright 0 Lindblad Architects 1998-2002 - All Rights Reserved

a r 25 04 0 2 : l O p Paul A Ironside, MD 760 346 5345

Exhibit # 3

Decision California Medical Board

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FOOTNOTES

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M a r 25 04 02:16p Paul A Ironside, MD 760 346 5345

Exhibit # 5

L. A. Times Articles

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linger below the surface,

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us Hospital

Officials admit tensions An American Church in TOM GORMAN, ERIC 1998. pg. 22

Terrahi; Doctors have departed with various complaints, from of outspoken colleagues.

have passed. Series: SHAKEN FAITH. in a two-part series:(Horhe Edition1

Los Angeles, Calif.: Aug 13,

Full Text (1059 word:)

Copyright, The Times Mirror Company; 1 s Angeles Times 19913 all Rights reserved)

Lorna Linda University Medical Center sta ds as one of the brightest marquees of the Seventh-day Adventist Church.

Hundreds of infants have been saved by @aft transplants pionei?reti by Lorna Linda doctors. The separation of Siamese twins in 1996-and the birth of a other set this year-have stirred t he hearts of parents everywhere.

A high-tech cancer treatment center has r i duced the debilitating side effects of radiation on patients. Personal- health research at the medical center has [promoted smarter lifestyle decisions.

I And the gallant-albeit controversial-effo to save newborn Baby Fasxi th the heart of a baboon in 1984 showed the world that Lorna Linda dared o make a difference.

But like the church itself, the hospital in thb town of Lorna Linda, 60 miles east of Los Angeles, has been beset by internal controversy over its style of rn nagement.

Dozens of physicians have left the 880-b medical center alleging everything from religious favoritism and blatant nepotism to the firing of outspoke doctors as a warning to others.

“One of the real difficulties with Adventis 1 is that the leadership feels they’re doing God’s work, so you can?

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argue with them,” said Dr, Alan Jacobson an Adventist who quit Loma Linda about seven years ago.

Some Say Anxieties Linger

Officials of the medical center that there have been some the departure of a number

“Certainly, Lorna Linda is not a perfect spirit of,Loma Linda is positive, is

Linda University, a health sciences institution, acknowledge at the Adventist-owned hospital have steadied since

said Lorna Linda University President Dr. L. Lyn Behrens. “But the we have the ability to solve problems in a way that is

professional and appropriate.”

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without a strong faculty organization, one ci lways has to be concerned about jeopardizing his job security."

Those concerns stem largely from a sene of tumultuous events that began in the early 1990s when two doctors formerly at the medical center sued Lorna Linda officials for allegedly stealing their potentially lucrative research- -a charge the school denied. f Three prominent doctors who were outsp ken in support of their colleagues eventually were fired, prompting more outcries. Two-thirds of the doctors i 4 the School of Medicine called for their reinstatement.

A letter of protest signed by 20 doctors cohcluded that "the church has long been known for integrity and honesty, and for preaching the Gospel-late the Lord thy God with all thy heart and thy neighbor as thyself. We believe that the manner in which this administration has dealt with many {employees} is in stark contrast to our

The American Assn. of University Profess rs weighed in too, cerisuring Lorna Linda in 1992 for the firings-a

motto to 'Make Man Whole.' "

censure that remains in place today, one of 55 from the group that are currently in effect nationwide.

Loma Linda administrators dismiss the as ociation as little more than a biased labor union and say its chief complaints about the handling of faculty g 'evances have been addressed.

b Although the doctors who alleged that the i r research was stolen have settled their cases out of court for undisclosed sums, wrongfut-discharge lawsuits filed by two of the fired physicians are heading toward trial.

Meanwhile, last summer the hospital's ne rosurgery residency program was piaced on probation by a national

instability" and that "faculty do not get along or collaborate effectively in the training of residents," jeopardizing their morale.

Lorna Linda officials say the problems arejbeing addressed. Another accreditation review is scheduled for next year,

Another physician, vascular surgeon Alan/Koslow, is suing the ho.,p ital, alleging that after an argument with a supervisor led to his 1993 departure, he as deemed incompetent by a Loma Linda physicians panel that

review-posted on a nationwide physicians databank-cost him a new job.

accreditation team. The group's report co 1 , cluded that the department's leadership suffered from "long-standiz,n

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secretly reviewed his work. Koslow, who 1 ad earlier received numerous accolades from Lorna Linda, said the

A subsequent independent study cleared oslow, concluding that "from the nature of the strictness with which his work was judged, there was somethin else afoot that does not really appear herein."

After the pejorative information was rem0 ed from the databank, a lower court judge dismissed Koslow's suit for financial darnages-a ruling the physician s appealing. Citing the oiigoing litigation, Lorna Linda officials declined co rnment. 1 I

I Probe of Contract Urged

In another episode, a former president of (he worldwide Seventh-d- ciy Adventis: Church told The Times that there should be a review of whether the awardi g of a lucrative contract was unduly influenced by family connections.

Neal Wilson, now a Lorna Linda trustee, said the contract could spark "views of nepotism, that there's a family tie-in here, a kind of royal succession. . . . Ii think there is an ethical question, definitely."

The contract-to maintain the hospital's prbton beam accelerator, a state-of-the-art device for radiation treatment-was awarded to the son of the fhairman of the radiation medicine department, The contract also -

1

gave the son's cornpa;;y axclusive rights technology acquired by and further devel the father and son have denied any wron

build and market proton accelerators internationally, using at Lorna Linda-a deal potentially worth millions of dollars. Both

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Wilson, the church's president from 1979 o 1990, has earned a repl;%tion for speaking his mind. But he saves his sharpest words for t h o s e who would c allenge the medical center 's adminisiration-a philosophy that seems embedded in the Seventhday Adventist i hurch itself.

Wilson said unequivocally that the medical center will not tolerate "a dissident type of mind'" that "sows t h e seeds

"if the situation demands it," he said, "the est way {to deal with it} is just to relieve people {of their jobs} . , . and

of discontent."

wish them well."

Credit: TIMES STAFF WRITERS

Reproduced with permission of t h e copyri ht owner. Further reproduction or distribution is prohibited without permission. Subjects: Locations: Lorna Linda California I Companies: Article types: Feature Section : PART-A; Metro Desk 1

IS SNIISBN: 04583035 Text Word Count 1059 I

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Lorna Linda University Medical Center-California, 'Seventh-day Adventist Church I

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U.S. Drops Inquiry of Simi H spital, Doctors; Medicine: The three physicians were accused of taking heafth facility.:D/entura

loans for referring patients to the

CARLOS V. LOZANO. The Los Angeies jrirnes (Pre-1997

Full Text (677 words)

Copyright, The Times Mirror Company; Lds Angeles Times

Fulltext). 10s Angeles, Calif.: Jun 27, 1992. pg. 1

1992a// Rights reserved)

Federal authorities have dropped a two-y ar investigation against Simi Valley Hospital and three pbysicians accused of referring patisnts to the medic I facility in the mid-19130s in exchange for non-repayable loans,

Hospital President Alan Rice called the d i cision an exoneration of the hospital and of the physicians, who still

hospital officials said Friday.

practice there.

"Our board of directors is pleased to see t is come to an acceptable conclusion," Rice said. "We can now focus all of our energies and resources on the community's health needs."

Rice said the U.S. Department of Health nd Human Services had informed the hospital recently that it had dropped its inquiry of the hospital and Drs George Dichter, Geoffrey Graham and Vahe Azizian.

Elliot Kramer, the federal inspector in chaige of the investigation, did not return calls to his San Francisco office 1

Friday. I

Rice said the hospital, as "a good-will ges i ure," agreed to pay $50,000 to the federal government to help cover the costs of the investigation, which involved a previous set of administrators at the hospital.

"They had quite an investigation and this J 4 as a way to help defray some of the' expenses," Rice said. "It was part of a good-faith effort."

The three physicians who were targeted in the federal inquiry were suspected of taking hundreds of thousands of dollars in non-repayable loans from theihospital in the mid-1980s in return for referring patients to the facility.

Darwin Remboldt, the hospital's chief adrqinistrator at the time, later testified before the Ventura County Grand Jury that the practice of giving doctors financial benefits for referring patients had been hospital policy.

Remboldt, who answered questions only fter being granted immunity from prosecution, said such practices were necessary for the hospital to aI2ra.d hysicians to fast-growing Simi Valley.

The 1990 grand j u r y report concluded that the hospital and the doc1:ors had violated state law, but county prosecutors concluded that no charges c 'uld be filed under state law because too much time had passed since t h e alleged crimes.

Because federal law allowed more time to file charges, Kramer's offke announced it would conduct its own investigation to determine whether there was sufficient evidence to pursue the case through the U.S. attorney's office. . The three physicians could not be reached for comment Friday. But Christopher Caldwell, an attorney representing Dichter and Graham, confirmed that the investigation h 2 5 been suspended and his clients cleared

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of any wrongdoing. I

"All three doctors have been relieved" of any claims against them, Cisldwell said. "What they are doing now is

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i practicing medicine and taking care of the r patients."

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Caldwell has maintained all along that hislclients received substantial loans from the hospital but never as part of an agreement to bring patients to the h ' spital. He said Graham and Dichter are still paying back the $300,000 loan they received from the medical facilit in 1986 to set up practice in Simi Valley.

"They are quality physicians," Rice said in I defense of the hospital's decision to offer the loans to attract the doctors. "This has never been an issue of the quality of care at the hospital."

Azizian, in an earlier interview, the agreement that the hospital

ed that he had received a $25,000 lban from the hospital in 1985 with at least part of the loan in return for patient referrals.

But Azizian said he continued to refer patients to other hospitals;. Like Dichter and Graham, Azizian said he, too, was in the process of payhg the hospital pack.

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Rice said the hospital still makes loans to Ioctors as an incentive to bring needed specialists to the area, but the loans must be paid back. I

Since Rice took over as president of the hospital in 1989, the medical facility has changed its name from Simi Valley Adventist Hospital to Sirni Valley H spital and has spent more than $5 million on new medical equipment and renovation work.

Rice said the name change had nothing t do with the investigation. He would not discuss the hospital's financial status, except to say that it was headed in a "favorable direction."

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